A city (or county) is not an accident but the result of coherent visions and aims

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include detailed quantitative and qualitative data, including estimates of the number of persons in each category, discussions 
of available and needed resources, identification of housing types and numbers, and analysis of specific needs for identified 
categories (
Gov. Code §65583(a)(7)
). 
Additional considerations and categories should be identified by each community and analyzed as appropriate. These may 
include transitional housing, assisted living, homelessness, and any other special housing needs specific to the jurisdiction. 
Consideration of homelessness specifically may affect estimates of needed housing. 
The need for emergency shelter
 must be 
assessed based on annual and seasonal need, and may be reduced by the number of supportive housing units that are identified 
in an adopted 10-year plan to end chronic homelessness. To be credited toward the need, these supportive housing units must be 
either vacant or have funding identified for construction during the planning period. 
For assistance with the analysis of housing needs, including a discussion of resources such as existing housing, services and 
needs, cities and counties should contact local service providers. These include continuum of care providers, local homeless 
shelter and service providers, food programs, operators of transitional housing programs, local drug and alcohol program service 
providers, county mental health and social service departments, local Salvation Army, Goodwill Industries, churches and schools. 
Additional information on local services and needs may also be available by contacting one of 15 countywide Designated Local 
Boards certified by the HCD’s Emergency Housing and Assistance Program.
Sites Inventory and Analysis 
Requirement Description:
Local governments must prepare an inventory of land suitable for residential development, including both vacant and non-
vacant sites, and an analysis of the relationship of zoning and public facilities and services to these sites (
Gov. Code § 65583(a)
(3)
 and 
65583.2
). The inventory must address the following components: 
Inventory of Land Suitable for Residential Development: 
The land inventory must identify specific sites suitable for the development of housing within the planning period that are 
sufficient to accommodate the jurisdictions share of the regional housing need for all income levels (
Gov. Code § 65583
). Land 
suitable for residential development includes vacant sites zoned for residential use, vacant sites zoned for nonresidential use 
that allow residential development, residentially zoned sites capable of being developed at a higher density, and sites zoned for 
nonresidential use that can be redeveloped for, and as necessary, rezoned for, residential use. The inventory may also list sites 
by characteristics such as city owned, proximity to services and amenities, infill and equity opportunity areas, transit and other 
priority development areas and areas potentially eligible for CEQA streamlining. Access to resources, including water, should also 
be considered (
Pub. Resources Code § 21094.5
,
 21155.1-21155.4
; 
CEQA Guidelines § 15183.3
).
Analysis of Sites and Zoning: 
The site specific listing must be accompanied by analysis to demonstrate that the land is suitable for development in the 
planning period and sites and zoning are sufficient and appropriate to accommodate the jurisdiction’s share of the regional 
housing need for all income levels. This analysis should include whether the impacts of a 
changing climate
 will affect 
the suitability of sites and zoning by subjecting sites to risks such as fire, flooding, sea level rise, seismic activity, etc. More 

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information on these risks can be found in the 
safety
 and 
climate change
 chapters. Including an analysis of sites identified 
by the previous housing element update, and the factors responsible for projected housing having been built or not built, may 
help jurisdictions plan with implementation in mind. The site inventory and analysis must be 
consistent
 with the 
land use
 
element and accompanying diagram. Analysis of sites coordinated with other elements of the general plan, including 
land 
use
, 
circulation
, and 
open space
, will help jurisdictions identify potential co-benefits toward their local goals. For example, 
identifying sites for higher density, mixed income, or low income housing near transit centers, active transportation routes, 
employment centers, services, or parks, may promote 
health
 and 
economic development
, reduce GHG emissions and 
climate 
change
 impacts, and assist in affordability and quality of life. 
Zoning for a Variety of Housing Types: 
The analysis of sites must indicate whether the inventory can provide for a variety of housing types, including multifamily rental 
housing, factory-built housing, mobile homes, housing for agricultural employees, transitional and supportive housing, single-
room occupancy units and emergency shelters. Providing development opportunities for a variety of housing types promotes 
diversity in housing price, style and size, and contributes to neighborhood stability by offering more affordable and move-up 
homes and accommodating a diverse income mix. Additionally, needs for housing types vary among jurisdictions, from high 
density needs in urban areas to smaller scale mid density rental housing, additional dwelling units, and other housing types in 
suburban and rural areas. Determining the analysis of a variety of housing types must account for a number of specific factors. 
This includes identification of zoning districts where each of the housing types are permitted, discussion of how development 
standards and processing requirements facilitate development of each of the housing types; and a description of capacity and its 
suitability to accommodate development or improvement opportunities 
In addition, the statute provides flexibility to local governments in identifying sites to accommodate their share of the regional 
housing need (
Gov. Code § 65583
). 
Adequate Alternative Sites:
Local governments can address up to 25 percent by income group of their adequate sites requirement, under prescribed 
conditions, including units that are substantially rehabilitated, converted from market-rate to affordable, or where the 
affordability of certain multifamily housing units are preserved.
Targeting Opportunity Sites
One purpose of the site listing is to allow the housing element to function as a working land use document, showing the 
community and developers where the City intends to target its growth and accommodate households for all income levels. 
Some jurisdictions identify sites by various characteristics to focus evaluation, resources, incentives and other actions to 
promote their intended use. For example, some jurisdictions may denote sites within priority development areas, transit 
priority areas, downtown areas, city-owned sites, areas meeting proximity criteria for funding (e.g., distance to amenities, 
infill, etc.).

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